Data transfers post Schrems

European_UnionTransfers of data from EU to US can still occur. The Article 29 Working Party has set a deadline of end of January 2016 for Safe Harbour 2.0 to be finalised. After this, depending upon what transfer methods are being used, the data protection authorities will start taking enforcement action.

The European Commission sets out how to ensure data transfers continue to be compliant with the Data Protection Directive:

  1. Contractual solutions including use of model clauses
  2. Intra group transfers under binding corporate rules
  3. Derogations – including consent by the data subject or it is necessary for the performance of a contract etc


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